Woodstock comment in support of a proposed Federal Reserve Board rule requiring the consideration of a consumer’s ability to repay the loan before making any consumer credit transaction

fed_july2011_R-1417_abilitytorepay_0.pdfComments submitted by Woodstock president Dory Rand to the Federal Reserve Board in response to a proposed rule for a Qualified Mortgage or QM. The comments support an obligation to verify, not just consider, the additional criteria. In addition, the comments request that underwriting be based on the maximum interest rate for the entire loan, not just the first five years.